HomeMy WebLinkAbout2007-3301 Civil
THOM E. LEWIS : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
V. :
:
PENNSYLVANIA DEPARTMENT OF :
TRANSPORTATION : 07-3301 CIVIL TERM
IN RE: APPEAL FROM VEHICLE REGISTRATION SUSPENSION
BEFORE BAYLEY, J.
OPINION AND ORDER OF COURT
Bayley, J., November 28, 2007:--
Thom E. Lewis filed an appeal nunc pro tunc (as allowed by an order dated
August 27, 2007) from the suspension for three months by PennDOT of the registration
for his 1993 Jeep pursuant to 75 Pa.C.S. Section 1786(d). A hearing was conducted
November 26, 2007
on . The notice of suspension was dated and mailed to Lewis on
February 6, 2006
, and was based on an electronic transmission to PennDOT from
December 12, 2005
Progressive Specialty Insurance Company on , certifying the
November 4, 2005 1 December 12, 2005
termination of insurance on the Jeep on . On ,
PennDOT had sent Lewis the following notice:
We recently received information from your insurance company about a
cancellation of your automobile insurance. We realize you may have only
changed companies; however, insurance companies are only required to
notify us of a cancellation of insurance but not when they add you as a
customer. Therefore, we need to verify your new coverage with this letter.
Please take the time to read this letter carefully and provide us with the
__________
1
Progressive’s notice to PennDOT was not within ten days from the cancellation date
of the insurance as required by 67 Pa. Code. 221.1(a).
07-3301 CIVIL TERM
Failure to respond to this letter within three
needed information.
weeks may result in a suspension of your vehicle registration.
December 12, 2005
On , Progressive sent petitioner a notice canceling his
November 4, 2005
policy effective , declaring that it was void as of that date because
March 10, 2006
Lewis’s check for the premium was not honored. On , Lewis filed a
complaint with the Insurance Department of Pennsylvania challenging the cancellation
of his insurance by Progressive. He asserted that he never received the December 12,
2005 notice of cancellation from Progressive, although he acknowledged that he
learned of the cancellation from his insurance agent on December 13, 2005. Lewis’s
complaint was dismissed as untimely. On appeal, the dismissal was upheld by the
Lewis v. Insurance Department,
Commonwealth Court. A.2d (2007 Pa.
Commw. Lexis 612, memorandum opinion filed August 28, 2007, and designed an
opinion on November 2, 2007). The court stated:
Tiffany Burton, an employee of Progressive who deals with cancellation
mailings to policyholders, testified that the termination notice was mailed
to Lewis in the regular course of business on December 12, 2005, that the
notice was sent to the address that Lewis had provided when he applied
for the insurance policy and that the notice contained the required
information regarding a right to request review by the Insurance
Commissioner within thirty days. To corroborate this testimony,
Progressive presented a copy of internal business documents
establishing the mailing of the notice to Lewis and a certificate of mailing
from the United States Post Office. Burton also testified that the notice
was not returned to Progressive as undeliverable.
* * *
Lewis’s mere denial that he received Progressive’s notice is not sufficient
to rebut the presumption that the December 12, 2005, notice was
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07-3301 CIVIL TERM
received. Id. Moreover, Lewis admitted that he had actual notice of the
policy termination on December 13, 2005, when his insurance agent
informed him of the fact. Therefore, the Insurance Commissioner
correctly found that Lewis’s March 10, 2006, request for review was
untimely and that she lacked jurisdiction to consider the merits of his
case. (Footnote and citation omitted.)
In the instant appeal, the record shows that Lewis obtained new insurance on his
December 16, 2005
Jeep from a company other than Progressive on , which was 42
days from the effective date of the cancellation by Progressive of November 4, 2005,
three days after Lewis learned of the cancellation from his insurance agent on
December 13, 2005, and four days after Progressive sent him notice of the cancellation
on December 12, 2005. PennDOT maintains that it was required to suspend Lewis’s
vehicle registration for three months pursuant to 75 Pa.C.S. § 1786(d) of the Vehicle
Code because he had no insurance for more than thirty days between November 4,
Beitler v. Commonwealth of Pennsylvania,
2005 to December 16, 2005. In
Department of Transportation, Bureau of Motor Vehicles,
811 A.2d 30 (Pa.
Commw. 2002), the Commonwealth Court stated that a cancellation of automobile
insurance is a termination of a policy prior to its expiration, and that the Insurance
Company Law of 1921, 40 P.S. §§ 991.2001-2013, provides in Article XX:
[t]hat a policy cancellation cannot be effected without prior notice. It
states:
A cancellation or refusal to renew by an insurer of a policy of
automobile insurance shall not be effective unless the insurer
delivers or mails to the named insured at the address shown in the
policy a written notice of the cancellation or refusal to renew.
The Court noted that challenges to an insurer’s action must be presented to the
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07-3301 CIVIL TERM
Department of Transportation, Bureau of Driver
Insurance Department. Citing
Licensing v. Riley,
150 Pa. Commw. 259 (1992), the Court stated that when PennDOT
seeks to suspend a vehicle registration for three months pursuant to Section 1786(d):
[t]o sustain its burden of proof, DOT must establish: (1) that the vehicle
in question is of a type required to be registered in the Commonwealth;
and (2) that the required automobile liability insurance had been
cancelled or otherwise terminated.” To sustain its burden of proof, DOT
must establish the policy period and whether it terminated on the twelve-
month anniversary date or at mid-policy. Next, it must show that in a
termination for non-payment of premium, a notice of cancellation was
sent, if required. In the absence of such notice, a cancellation is not
effected and the predicate act for suspending a registration has not
occurred. (Footnote omitted.)
* * *
[t]he requirements of the Vehicle Code means that DOT must prove that
an insurance policy cancellation has been effected. DOT does not meet
its burden of proving that the vehicle owner was without insurance
coverage for 31 days until it proves that the insurer sent a notice of
cancellation or non-renewal.
sub judice,
In the case Progressive did not send a cancellation notice to Lewis
until December 12, 2005, which was already 38 days after the effective date of the
cancellation effective November 4, 2005. Thus, Lewis could not have purchased new
insurance within 30 days of the effective date of the cancellation and avoided a three
month registration suspension even if he would have been able to certify that he did not
operate or permit the operation of the Jeep during the period of lapse in financial
responsibility. See 75 Pa.C.S. § 1786(d)(2). Notwithstanding, because Lewis was
without insurance for more than thirty days and Progressive sent him notice of the
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07-3301 CIVIL TERM
cancellation, PennDOT was required to suspend his vehicle registration for three
months.
ORDER OF COURT
AND NOW, this day of November, 2007, the appeal of Thom E. Lewis
IS DISMISSED.
from the appeal of the registration for his 1993 Jeep for three months,
By the Court,
Edgar B. Bayley, J.
Thom E. Lewis, Pro se
263 Texaco Road
Mechanicsburg, PA 17055
George Kabusk, Esquire
For Department of Transportation
:sal
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THOM E. LEWIS : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
V. :
:
PENNSYLVANIA DEPARTMENT OF :
TRANSPORTATION : 07-3301 CIVIL TERM
IN RE: APPEAL FROM VEHICLE REGISTRATION SUSPENSION
BEFORE BAYLEY, J.
ORDER OF COURT
AND NOW, this day of November, 2007, the appeal of Thom E. Lewis
IS DISMISSED.
from the appeal of the registration for his 1993 Jeep for three months,
By the Court,
Edgar B. Bayley, J.
Thom E. Lewis, Pro se
263 Texaco Road
Mechanicsburg, PA 17055
George Kabusk, Esquire
For Department of Transportation
:sal